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Food Packaging and the FSMA

Lot and date information embedded in bar codes

The Food Safety Modernization Act that was signed into law in January 2011 made major changes regarding the way food is tracked. A big part of this law deals with documenting processes and inventory in food production, and that includes the packaging used for storing and shipping food products. In addition to Country of Origin (COOL) and nutrition labeling, packagers must also comply with FSMA requirements.

Packaging that touches food is treated as food. So any type of plastic or foil package, can, or box that comes into contact with the food product must be labeled with lot information. That lot information and other data is then captured and tracked along the supply chain as it is used with the food product and can be tracked back to the packaging vendor if necessary.

The packaging in which finished food products are shipped, or outer packaging, must be tracked as well. Lot numbers or manufacturing dates are required. For example, when a container full of boxed pasta is shipped, the receiver must collect the lot number, manufacturing date or expiration date of the lot, and the size of the pasta boxes. This information is provided on the outside of the container and allows for tracking the food (and packaging) through any further production or shipping, and then that information is provided to the consumer.

Are you involved in packaging and need to comply with the new food labeling requirements? Then give us a call. We can help you find a labeling solution to meet requirements and avoid the costs associated with mock or actual recalls.


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  1. If you have a customer that sends you a label and it is in a language that you can’t translate. Would you have to have a 3rd party certified translator or could you ask that customer to provide you with the translation. If you received the translation from the customer how would you know that it is accurate to what they are saying. For example you are a non Organic company but the translation had an Organic statement. how can you validate that the information on the label is not going to expose the packer and its name to unnecessary risk or harm.

  2. David Holliday says:

    That’s a great question, Kathryn, but outside of our area of expertise.
    I thnk that’s something you probably need legal advice on.

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